¾¾Text Clarifications and Policy Changes in Response to Comments received on the Draft LUCE May 14, 2010 In addition to comments on the EIR and verbal comments during Planning Commission and City Council study sessions, written comments were received on the Draft LUCE document from: 1. Santa Monica Auto Dealers Association 2. Santa Monica Chamber of Commerce 3. Community Corporation of Santa Monica 4. Saint John’s Health Center 5. Santa Monica Landmarks Commission and Santa Monica Conservancy 6. Comments received on the City Yards 7. Crossroads School of the Arts and Sciences 8. Main Street Merchants Association 9. Policy changes from LUCE EIR While the Draft LUCE establishes much more detailed prescriptive standards than prior General Plan elements, some comments suggest that a number of policies in the LUCE should provide additional implementation criteria. The General Plan is considered the constitution for future development whereas the Zoning Ordinance is considered the primary means for implementing the General Plan. Consistent with this hierarchy, the Zoning Ordinance will provide for greater specificity, detail and refinement than is provided in the General Plan to implement the LUCE goals and policies after it is adopted. This also allows the needed flexibility so the implementing regulations of the Zoning Ordinance can be refined and adjusted as new issues, uses and technologies evolve over time. Nevertheless ...
Text Clarifications and Policy Changes in Response to Comments received on the Draft LUCE May 14, 2010 In addition to comments on the EIR and verbal comments during Planning Commission and City Council study sessions, written comments were received on the Draft LUCE document from: 1. Santa Monica Auto Dealers Association 2. Santa Monica Chamber of Commerce 3. Community Corporation of Santa Monica 4. Saint Johns Health Center 5. Santa Monica Landmarks Commission and Santa Monica Conservancy 6. Comments received on the City Yards 7. Crossroads School of the Arts and Sciences 8. Main Street Merchants Association 9. Policy changes from LUCE EIR While the Draft LUCE establishes much more detailed prescriptive standards than prior General Plan elements, some comments suggest that a number of policies in the LUCE should provide additional implementation criteria. The General Plan is considered the constitution for future development whereas the Zoning Ordinance is considered the primary means for implementing the General Plan. Consistent with this hierarchy, the Zoning Ordinance will provide for greater specificity, detail and refinement than is provided in the General Plan to implement the LUCE goals and policies after it is adopted. This also allows the needed flexibility so the implementing regulations of the Zoning Ordinance can be refined and adjusted as new issues, uses and technologies evolve over time. Nevertheless, the following responses provide clarification on provisions already in the Draft LUCE and in some instances, changes to text or policies in the Draft LUCE have been made. These are indicated with underlined text. 1. Santa Monica Auto Dealers Association and Santa Monica Chamber of Commerce: ¾ The LUCE proposes discretionary review to approve projects over the base height and FAR up to the maximum 35 foot height and 1.5 FAR, the same height and FAR allowed in Interim Ordinance 2264. The LUCEs discretionary threshold is less restrictive than Interim Ordinance 2264s discretionary review threshold. The LUCE also proposes a ministerial process when detailed design standards are adopted for the urban auto dealer format described in the 20th Street to Lincoln Boulevard section of the Santa Monica Boulevard description on page 2.4 ‐ 14 (Chapter 2.4 Boulevards). Application by auto dealers wishing to redevelop and expand their dealership before the urban auto dealer format standards are refined and codified will be processed with a discretionary process that will include review of the design for consistency with the LUCE. ¾ The following modifications to development parameters and text clarifications are recommended:
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o Pages 2.1 ‐ 36 Modify Development Parameters for General Commercial (Santa Monica) Tier 1 ‐ Base Height The base height in the General Commercial portion of Santa Monica Boulevard is 25 32 feet (2 stories) with a 1.25 FAR. For purposes of calculating FAR, The FAR of below grade auto dealer facilities shall be excluded does count toward allowed FAR and rooftop parking/automobile storage shall be is discounted by 50%. calculated at 50 percent of actual. Residential use is discouraged. o Page 2.1 ‐ 32 Modify text for Mixed Use Boulevard Low (Santa Monica and Broadway) To meet the changing demand for automobile sales uses, existing automobile dealers shall be allowed to expand using the urban auto dealership format described in the 20th Street to Lincoln Boulevard section of the Santa Monica Boulevard description (on page 2.4 ‐ 14), and in a manner that is respectful of their surrounding neighbors. Auto dealers that do not expand are encouraged to transform their dealerships into the urban auto dealership format which contributes to Santa Monicas urban form with multi ‐ story buildings built to the street and parking in structures at the rear or underground. For purposes of calculating FAR, below grade auto dealer facilities shall be excluded and rooftop parking/automobile storage shall be discounted by 50%. The existing auto dealer parking/automobile storage use on Broadway may continue, but dealerships are encouraged to move parking/storage on ‐ site when they convert to the multi ‐ story urban auto dealer format. o Page 2.1 ‐ 34 Modify text for Mixed Use Boulevard (Wilshire and Lincoln) Existing automobile dealerships may continue or be revitalized using the urban auto dealership format described in the 20th Street to Lincoln Boulevard section of Santa Monica Boulevard. Existing automobile dealers shall be allowed to expand using the urban auto dealership format described in the Strategic Approach for 20th Street to Lincoln Boulevard on Santa Monica Boulevard (Chapter 2.4 Boulevards), and in a manner that is compatible with the surrounding neighborhood. Auto dealers that do not expand are encouraged to upgrade their dealerships into the urban auto dealership format, which contributes to Santa Monicas urban form with multi ‐ story buildings built to the street and parking in structures at the rear or underground. For purposes of calculating FAR, below grade auto dealer facilities shall be excluded and rooftop parking/automobile storage shall be discounted by 50%. ¾ The LUCE supports auto service/storage in the Industrial Conservation District (Policy D27.5) and west of 20 th Street on Colorado Boulevard (Policy B14.4), but recommends new auto sales facilities to be located on Santa Monica Boulevard between Lincoln Boulevard and 20 th Street. However, limited car sales could be allowed at existing service facilities pursuant to a discretionary process. o Modify Policy B14.4 to read:
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2.
Maintain service/storage facilities for automobile dealerships as permitted uses west of 20th Street. A discretionary approval process may be implemented to authorize auto sales at existing dealership service and storage facilities. Santa Monica Chamber of Commerce: ¾ Height in Non ‐ Residential Districts o The Mixed Use Boulevard designation requested by the Chamber was initially proposed for the eastern portion of Santa Monica Boulevard. The proposed Mixed Use Boulevard Low designation is based on extensive public hearing discussions of the Strategy Framework. o Portions of Pico Boulevard that have enough depth to physically be developed per the Mixed Use Boulevard Low designation are in that classification. However, most parcels have similar size and access constraints to Lincoln Boulevard and are best suited for the Neighborhood Commercial designation. o Clarification to Goal HP2 will address concerns that discretion is available to approve additional height if necessary to accommodate the preservation of on ‐ site historic resources. This issue is addressed in the Landmarks Commission/Santa Monica Conservancy comments, below. o For the Bergamot and Mixed Use Creative districts, the Chamber recommends additional height should be allowed if reasonably necessary to accommodate publically accessible open space, provided the additional height is setback a reasonable distance from the street front and residential zoning district. The Chamber is also concerned that the standards for Wilshire Boulevard are overly restrictive. The letter tentatively suggests that the Tier 1 base allow 2 stories of commercial or three stories for mixed ‐ use projects. These development standards were developed through an extensive community process that was intended to provide the community the greatest ability to shape urban form and to require meaningful community benefits from new development. In addition, the building heights and intensities, particularly along the boulevards, were intended to balance the ability for property owners to have viable projects with the need to provide a reasonable measure of certainty that adjacent neighborhoods and residential properties are protected one of the fundamental principles of the LUCE. o Add a bullet to the General Commercial Development Parameters for Lincoln Boulevard to read: On Lincoln Boulevard south of I ‐ 10, existing, moderately ‐ priced motels should have no limitation on the number of stories so long as they comply with established height limits. o For clarity, the LUCE does not limit the number of stories for residential or hotel projects so long as they comply with the height limit in commercial districts. ¾ LUCE Tiering Structure and As ‐ Of ‐ Right Development o The Chamber does not appear to endorse the community benefit tier structure of the LUCE. The community benefit tier structure is a central feature of the Draft LUCE and is intended to ensure that buildings above the base height will provide significant
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community benefits. It is designed to enable the community to have the greatest opportunity to shape urban form. ¾ Density o Except for portions of Santa Monica, Lincoln and Pico Boulevards discussed above, the Chamber generally supports the FARs in the draft LUCE. ¾ Design o Where the LUCE uses specific design standards, such as a 25 foot street wall facing most boulevards, it also specifies that rooflines need to be varied, buildings need to be articulated with offsets, projections, and setbacks to achieve well designed buildings. Accordingly, the LUCE requires design flexibility that will be refined and implemented through the Zoning Ordinance. The issue of design flexibility is also addressed in the Architectural Review Boards comments, below. ¾ Housing o The Chamber recommends doubling the floor area devoted to housing in favor of the FARs identified in the LUCE. The existing FAR structure in the Downtown District is based on a doubling of floor area devoted to residential use. Add new text to Downtown Core Development Parameters on Page 2.1 ‐ 44 (Chapter 2.1 Land Use Policy) to read: The height and FAR along with other development standards such as setbacks and step backs for the Downtown designation will be determined through a Specific Plan process. The new Downtown Specific Plan should consider and evaluate the continuation of the existing 50% floor area discount for residential uses in locations where it will be compatible in mass and scale with adjacent development. Prior to the completion of a new Downtown Specific Plan, the existing Bayside District Specific Plan and applicable land use designations will apply. o A flexible approach to workforce housing that focuses on unit type, marketing/outreach (occupancy by local workers) and not unit pricing or occupant income. Add text to last paragraph on Page 3.3 ‐ 10 (Chapter 3.3 Housing) to read: When the City develops a workforce housing program as part of implementing ordinances, factors to be considered may include local workforce preference and unit type, size , and mix in addition to conventional thresholds such as income eligibility and rent/sales price restrictions. o A flexible approach to affordable housing incentives including allowing the payment of affordable housing fees used to provide affordable housing off ‐ site. The LUCE does not change the Citys existing Affordable Housing Production Program, which allows fulfillment of affordable housing obligations through payment of affordable housing fees for all projects in commercial districts, rental projects in multi ‐ family districts, and ownership projects in multi ‐ family districts of less than 4 units. While the LUCE contains many policies that support the Housing Element, and paying affordable housing fees is consistent with current policy, affordable housing production policy is best placed in the Housing Element to ensure consistency between the elements. ¾ Auto Dealers : Comments regarding auto dealer uses are coordinated with the Santa Monica Auto Dealers Association comments, above. Page 4 of 15